Privacy Policy

This Privacy Policy will be effective from April 1, 2022.

Please read TROMF Software's Privacy Policy before using TROMF Software's services as it will let you know how we collect, store, use and disclose your personal information when providing our services to you.

If you have questions or complaints regarding our Privacy Policy or practices, please see Contact Us.

1. Introduction

TROMF Software develops and publishes social games for the web and mobile devices (the “Service”). "TROMF Software," or "we" or "us" refers to TROMF Software SRL in this Privacy Policy.

TROMF Software is committed to protecting the privacy of its users and provide them a better social gaming experience ("users" or "you"). This Privacy Policy has been created to inform you about how TROMF Software manages, collects, stores, shares, uses and protects the information you provide in connection with any TROMF Software game or application whenever you play our games or otherwise access any of our Services, products, content, tromf.ro and/or the other domains provided by TROMF Software.

This Privacy Policy applies whenever you play our games or otherwise access any of our other products, services, content, tromf.ro and/or the other domains provided by TROMF Software, together referred to as "Services." This Privacy Policy describes:

• Information We Collect and How We Collect It
• How We Use the Information We Collect and Our Legal Bases for Processing It
• How We Share Your Information
• Your rights and How to Access, Update and Manage Your Personal Information
• Privacy Policies of Third Party Services and Advertisers
• Our Policies Concerning Children
• How Long We Keep Your Information
• Security of Your Information
• Changes to Our Privacy Policy
• Contact Us

By using the Service, you agree to the collection, disclosure, storage and use of your information as outlined in this Privacy Policy. If you do not want TROMF Software to collect, store, use or share your information in the ways described in this Privacy Policy, you should not play TROMF Software’s games or use our Services. TROMF Software may amend the Privacy Policy from time to time, and TROMF Software encourages you to consult the Privacy Policy regularly for changes.

Users in certain jurisdictions have a right to access personal information held about themselves. Your right of access can be exercised in accordance with applicable law.

2. Information We Collect and How We Collect It

If you play TROMF Software's games or access any of our other Services on connected third-party applications or connect our Services to any third-party applications, including social networks like Facebook, TROMF Software may receive certain information about you from the provider of the third-party application. The information we receive depends on the TROMF Software game you're playing, the third-party application, your privacy settings and, if applicable, your friends' privacy settings on that third-party application.

For example, TROMF Software may collect and store some or all of the following information shared by the provider of the connected third-party application:

• your first and last name;
• your profile picture or its URL;
• your user ID number (like your Facebook ID number), which may be linked to publicly-available information like your name and profile photo;
• the login e-mail you provided to that third-party application when you registered with it;
• other publicly-available information on the third-party application; and/or
• any other information that you or the provider of the third-party application share with TROMF Software.

If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application's Terms of Service and Privacy Policy.

If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

Cookies and Automated Information Collection

We and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as:

• cookies, which are small pieces of data transferred to your mobile device or computer for record-keeping purposes;
• web beacons, which let us know if a certain page was visited or whether an e-mail was opened;
• tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively;
• and local shared objects, also known as flash cookies, which help us to reduce fraud, remember your in-game preferences and speed up load times.

We and our service providers use these log files, tags, and tracking technologies to collect and analyze certain kinds of technical information, including:

• IP addresses;
• the type of computer or mobile device you are using;
• your operating system version;
• your mobile device's identifiers, like your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
• your browser types;
• your browser language;
• referring and exit pages, and URLs;
• platform type;
• the number of clicks on a page or feature;
• domain names;
• landing pages;
• pages viewed and the order of those pages;
• the amount of time spent on particular pages; and
• game state and the date and time of activity on our websites or games.

In some cases, we will connect this information with your social network ID or TROMF Software user ID.

Please note that companies delivering advertisements on our Services may also use cookies or other technologies as described below in Third Party Advertising Including Tailored Advertising and Analytics, and those practices are subject to those companies' own policies.

For more information on how to limit the types of cookies you allow, please see Opting out of Cookie Tracking.

Information About You That You Share With Us Directly

When you use our Services (whether through a social network or through TROMF Software directly), you may give us information directly (like when you're setting up your account) and we will store that on our systems and use it for the purposes described in this Privacy Policy.

Some games or parts of our Services may use a more traditional registration or account set-up process where you may be asked to give us some or all of the following information:

• your first and last names;
• your e-mail address;
• a password; and
• other information that helps us make sure it's you accessing your account or helps us improve our services.

We may also let you create a player profile, separate from your social networking site profile (for example, your Facebook profile), that other TROMF Software players can see. Your player profile may include information like:

• a profile photo;
• game username(s);
• your gender;
• biographic details (like your age or age range);
• approximate location information that you provide;
• links to your profiles on various social network;
• details about the games you play; and
• a TROMF Software player ID number that is created by TROMF Software and used to identify your profile.
• Certain information in your TROMF Software profile may be publicly accessible on TROMF Software's websites that offer direct access to TROMF Software games, including:
• The TROMF Software player ID;
• Your first and last names; and
• Your player profile picture.

Except for games designed for children under 13, your TROMF Software player ID number used to identify your account and player profile will appear in the URL of your profile page. It will only allow access to information you make public in your settings.

Information You Generate Using Our Communications Features

Except for games designed for children under 13, you may be able to take part in certain activities on our Service that let you communicate or share information not just with TROMF Software, but also with other TROMF Software players. These include:

• participating in player forums and message boards;
• posting public comments to other players' profiles or gameboards;
• sending private messages or invitations to other players, either directly on our websites or to their e-mail accounts;
• chatting with other players; and/or
• posting photos or drawings.

You acknowledge and expressly agree that we may access in real-time, record and/or store archives of these communications, comments, photos and drawings on TROMF Software's servers to make use of them to protect the safety and well-being of our players and TROMF Software's rights and property in connection with our Services; to conduct research; to operate, improve, personalize and optimize our Services and our players' experiences, including through the use of analytics; and to manage and deliver contextual advertising.

Payment Information

If you purchase a license to use in-game virtual currency or virtual items in a game you play on tromf.ro, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address and financial information. TROMF Software does not collect or store your financial information, like credit card numbers. However, TROMF Software's payment processors may share non-financial information with us related to your purchases, like your name, billing address and the items purchased in order to fulfill your order. TROMF Software may also obtain the billing and payment information that you provide when your purchase is processed by someone else (like Facebook, Apple or Google) such as when you purchase something in a game you play on a social network or that you downloaded on your mobile device. Our Terms of Service explain our policies and terms relevant to our charges, billing practices, third-party credits and virtual currencies. Please note that purchases of third party credits or currencies may also be subject to those parties' policies.

Customer Support Correspondence

Except as provided herein, when you ask for help from our Customer Support team, we will collect and store the contact information you give them (generally, your name and e-mail address), information about your game play or activity on our Services, and your TROMF Software player and/or social network ID number. We will also store the communications you have with the Customer Service team and any information in those communications in order to provide support and improve the Services. For users of our games designed for children under 13, we will use your contact information for the sole purpose of providing a one-time response to your question. We will then delete your information from our servers.

Other Sources

We may collect or receive information about you from other sources like third-party information providers. We use this information along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.

3. How We Use the Information We Collect and Our Legal Bases for Processing It

The main use of the information we collect and store is to provide you with the Services you request from us and to improve your gaming experience, but there are other uses as well. The uses for which we collect and store your information include:

• to operate, improve and optimize our Services and our players' experiences;
• to create your game accounts and allow you to play our games;
• to identify and suggest connections with other TROMF Software players and personalize our Services to you;
• to enable players to communicate with each other;
• to provide technical support and respond to player inquiries;
• to protect the safety and well-being of our players;
• to protect TROMF Software's rights and property in connection with our Services;
• to prevent fraud or potentially illegal activities, and to enforce our Terms of Service;
• to manage and deliver contextual and behavioral advertising;
• to notify players of in-game updates, new products or promotional offers;
• to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties; and
• to conduct research.

One important use of your information is communication. If you have provided your e-mail address to TROMF Software, we will use it to respond to customer support inquiries, and keep you informed of your in-game activity, including comments from friends, let you know about in-game status. Some messages, like invites for friends to join you in a game, may include your name and profile photo. We may also send promotional e-mail messages and promotional SMS messages (e.g. text messages) ("Promotional Communications").

If you are located in the European Economic Area (“EEA”), our legal basis for collecting and using the information described above depends on what the information is and the context in which we collect it.

However, we’ll normally collect information from you only where we need it to perform our contract with you (i.e., our Terms of Service), where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights), or if we otherwise have your consent.

In some cases, we may also have a legal obligation or need to collect information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, another player).

If we ask you to provide information to comply with a legal requirement or to perform a contract with you, this will normally be clear from the context in which we are asking you to provide your information (for example, when we ask you to provide a username to access our Services, this will be to create an account for you in accordance with our Terms of Service), and, if not, we will provide an explanation to you at the relevant time. We will also make clear whether providing information is mandatory.

Similarly, if we collect and use your information in reliance on our legitimate interests (or those of any third party), it will be made clear to you at the relevant time what those legitimate interests are (such as personalizing our services and marketing, for example).

If you have questions or need further information about the legal bases on which we collect and use your personal information, please Contact Us.

4 How We Share Your Information

We may disclose or publish aggregated information (information about you and other players collectively that is not intended to specifically identify you, for example, players between the ages of 21 and 25 who live San Francisco) and other non-personal information about our players for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.

In addition, we may share your information (which may include personal information) with third parties (in other words, parties other than TROMF Software) or allow third parties to collect this information from our Services in the following circumstances:

Your Consent

With your consent, we may share your information with third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy.

Friends and Other TROMF Software Players

The Service supports and often encourages you to interact with other players. In most TROMF Software games, if you play through a social network or register through a social network (for example, Facebook Connect), your social network friends will see your name, profile photo and descriptions of your game activity. Similarly, in many TROMF Software games, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your game activity (including the identification of any TROMF Software games you have played), communicate with you within our Services, and view your game profile, which may include your name or a "game name" and your profile photo. For example, in Cruce, any other player may see your game profile if you are playing at the same table. In certain cases, your profile photo can reveal your social network ID or TROMF Software player ID, and access to a social network ID or TROMF Software player ID may allow others to view the public information associated with your related social network profile or TROMF Software account. Other players may also be able to send you game requests or even friend requests through the related social network's or TROMF Software's communication channels.

Third-Party Advertising Including Tailored Advertising and Analytics We have advertising on our Services so we can continue to offer many of our Services for free.

We do not actively share personal information with third-party advertisers for their direct marketing purposes unless you give us your consent.

When advertisers or ad networks place ads in our Services, they may collect or we may share the following types of information from within our Services:

• performance data (like the number of clicks on an advertisement);
• aggregated and/or de-identified information about you and other players collectively that is not intended to specifically identify you (like players between the ages of 21 and 25 who live San Francisco);
• certain technical information (for example, IP addresses, non-persistent device identifiers such as IDFAs, and de-identified persistent device identifiers such as a hashed Android ID);
• your social network ID;
• and other contextual data about your game play (for example, your level and session length)
• The information collected may be used to:
• measure how effective ads are, to offer you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising), and/or
• undertake web analytics (like Google Analytics which is used to analyze traffic and other player activity to improve your experience).

Advertisers or ad networks may collect this information through the use of tracking technologies like browser cookies and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time.

Please note, after clicking on a third party advertisement, you may no longer be on a site hosted by TROMF Software or the social network through which you are playing TROMF Software's games.

Safety, Security and Compliance with Law

Your information, and the contents of all of your online communications in our Services and between You and TROMF Software may be accessed and monitored as needed to provide our Service and may be disclosed:

• when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant or subpoena);
• to satisfy any laws or regulations that apply;
• where we believe in our sole discretion that the Service is being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
• when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and
• to protect the rights or property of TROMF Software and other applicable third parties, including to enforce our Terms of Service.

Third-Party Service Providers

We will share your information with third-party companies to perform services on our behalf, like processing payments, analyzing data, optimizing game play, e-mail delivery, hosting services, customer service and to help us in our marketing efforts, including managing and delivering contextual and tailored advertisements. We contractually require these third-party service providers to maintain the confidentiality of the information we share with them, and we contractually require them not use your information for anything other than to provide services on our behalf.

Sale or Merger

In the event that TROMF Software undergoes a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part its assets (like selling a game), we may disclose or transfer all of your information, including personal information, to the successor organization in the transition.

5. Your rights and How to Access, Update and Manage Your Personal Information

European Countries’ Users’ Rights

If you are located in the European Economic Area (“EEA”), you have the following data protection rights:

• You can review or request change or deletion of your personal information by contacting us through contact@tromf.ro, and we will respond to your request within thirty days.
• You can correct or update your personal information, object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

To exercise your rights to access or deletion, please contacting us through contact@tromf.ro. If you have any problems or would like to exercise any of your other rights, you can Contact Us. We respond to all data protection requests we receive in accordance with applicable data protection laws.

If you want to review or delete personal information associated with your game account data, please contacting us through contact@tromf.ro.

For deletion requests, we will take reasonable measures to delete your personal information from our records. If you have sent content through or posted content on the Service, we may not be able to delete it. We will keep certain records (e.g., personal information relating to payments or customer service matters) where we need (and have rights) to, such as for legal or accounting purposes. We’ll also keep information in order to exercise, defend, or establish our rights.

Information We Receive From a Third-Party Application Where You Play Our Games or From Your Mobile Device

To manage the information TROMF Software receives about you from a third-party application where you play our games, like Facebook, you will need to follow the instructions for the third-party application for updating your information and changing your privacy settings. The privacy management tools for applications on Facebook can be found here. To review and update information associated with your TROMF Software game profile in certain games, visit the "settings" page in that game. You also can manage some aspects of information collection and use by visiting the "settings" page of your mobile device and reviewing the permissions of each application or "app."

Once TROMF Software receives your information from a third-party application or your mobile device, that information is stored and used by TROMF Software in accordance with this Privacy Policy. You may access and update that information as described below.

Opting Out of Cookie Tracking

You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

If you disable cookies, you may lose some of the features and functionality of our Services because TROMF Software cookies are necessary to track and enhance your game activities.

6. Privacy Policies of Linked Third-Party Services and Advertisers

Our websites and games may contain advertisements from Third-Party Services, which are companies other than TROMF Software that may link to their own websites, online services or mobile applications. We are not responsible for the privacy practices or the content of these Third-Party Services. If you have any questions about how these Third-Party Services use your information, you should review their policies and contact them directly.

7. Our Policies Concerning Children

Generally speaking, most of our Services are not intended for children under the age of 13 (or under 16 for children located in the EEA) (collectively, “Children”). Children are not permitted to use these Services, and we do not knowingly collect any personal information from Children.

Though our Services do not target Children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. For users who identify themselves as Children in our age-gate on such Services, if we allow Children to use the Services, we will either provide a version of that Service that does not collect, use, or disclose “personal information” (as defined in the Children’s Online Privacy Protection Act (“COPPA”)), except as permitted by COPPA, or obtain legally valid parental consent.

If we learn that we have inadvertently gathered personal information that is not subject to a COPPA exception from a Child, we will take reasonable measures to promptly remove that information from our records.

8. International Operations and Transfers Out of the EEA

When you use Our Services, your data may be sent to other countries.

As part of our international operations, we may transfer data to our Affiliates (which means subsidiaries, parent companies, joint ventures and other corporate entities under TROMF Software group from time to time for our legitimate business purposes.

We store information about players and visitors to our sites on servers located mainly in the European Economic Area (“EEA”), and we may also store this information on servers and equipment in other countries within the scope permitted by applicable law. Personal data collected within the European Economic Area (“EEA”) may be transferred to, and stored at, a destination outside of the EEA within the scope permitted by applicable law.

The data we hold may also be processed by employees operating outside of the EEA who work for us or one of our Affiliates or for one of our vendors. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support services. When we transfer your personal information internationally we will take reasonable steps to ensure that your personal information is treated securely, lawfully and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.

If you are a resident in a jurisdiction, where transfer of your personal information to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer for us to provide you with our services.

9 How Long We Keep Your Information

How long we retain your information depends on why we collected it and how we use it. We will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.

We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take reasonable measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.

10. Security of Your Information

We implement security measures to help protect the security of your information both online and offline. We take steps to ensure that your data is treated securely and in accordance with this Privacy Policy. These measures vary based upon the sensitivity of your information.

While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk. If you have questions about the security of our websites, please contact us at contact@tromf.ro.

11. Changes to Our Privacy Policy

If we decide to make material changes to our Privacy Policy, we will tell you and other players by placing a notice on tromf.ro or its equivalent in-game, or by sending you a notice to the e-mail address we have on file for you prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums and on other TROMF Software websites. You should periodically check this privacy page for updates.

12. Contact Us

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to contact@tromf.ro.